Need to return call by / at/between and

. Signature: Project No.: 

### 0172.08.005.6 07 Page 1 of 1
Project Name: 

### 2011 Prelim Cat Rev 

## CBI? Yes No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 10/18/11 Time: 

### 4:00 am pm

Company Name: 

### Proctor and Gamble ERG Staff Name: 

### Kimberly Landick

Contact Name: 

### Michael Childress Contact Phone Number: 

### (570) 833

- 3306
General Subject: 

### 2009 TRI Dioxin Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On October 18, 2011 at 4:00 pm I called Michael Childress and left a message.

On October 19, 2011 at 10:20am, Mr. Childress returned my call. He stated that the facility has had no major changes in pulp bleaching operat ions between 2005 and 2009. He requested that the rest of the questions be sent via email so that he could verify the data. Email address: childress.mg@pg.com . Please see attached email correspondence.

### Proctor & Gamble, Mehoopany, PA Email Correspondence

From: Kimberly Landick To: childress.mg@pg.com Date: 12/07/2011 11:58 A M Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for your response. At this point we have no further questions. We will contact you if further questions arise.

Thanks again, Kimberly

From: Michael Childress To: Kimberly Landick Date: 11/30/2011 2:34 PM Subject: RE: Request for 2009 TRI Data Clarification

Dear Kimberly

– in response to your questions:

a. Question 1: What is the P&G pulp analysis data based on? For TRI reporting purposes, the pulp congener analysis data are based on the best available data. Depending on the pulp, these data may come from: direct sampling from the pulp vendors; National Council for Air and Stream Improvement (NCASI) data; or from conservative estimates based on other pulps from the same supplier. P &G obtains pulp sampling data directly from the pulp vendors (when possible) and do NOT do any P&G testing for these values. P&G considers the direct sampling data from the pulp vendors to be the best data; however, when that data are not available the NCA SI data or conservative estimates are used.

b. Question 2: Could we release a copy of the data?

i. P&G and its pulp suppliers consider this pulp characteristic data proprietary, so we don’t intend to release data on our entire pulp supply used at our Mehoopany facility. We have enclosed data (see below) on ONE of the species of pulp in our 2009 P&G Mehoopany TRI report so that you may have a representative sample to answer your question.

c. Question 3: What is the source of the estimated release amounts and could y ou receive a copy? i. The estimated release amounts are simply the multiplication of pulp congener concentration (from Question 2) TIMES the tonnage of this pulp used at our facility in 2009 which will yield net grams of dioxin released to the environment fr om this pulp species. ii. P&G considers the total capacity of pulp we consume annually at a facility proprietary (because that is a direct release of our manufacturing capacity and utilization); However, in order to answer your question, we will continue with the same approach used in Question #2

– we will provide data on tonnage of ONE of the pulps we used in 2009 (see under column... annual purchased pulp )

– same species as the concentration analysis that we referred to in Question #2;

1. We used xxx Tons of YYY P ulp. Therefore if we take the amount of this pulp species tonnage used in 2009 and using the various congener concentrations (table below) summarized the net grams of each dioxin congener generated in 2009. This of course is simply the multiplication of co ngener concentration (from Question #2) times the tonnage in Question #3 yielding net grams of dioxin released to environment.Impor ted or

Not Impor

ted Annual Purcha

sed Pulp (ADM

T) Total Dioxin (grams/

yr) Suppl ier Fiber Type Dioxin Congeners EPA Label Diox in Dat

a (ppt

) Annu al Dioxi

n Cont ent (MT) Annu al Dioxi

n Conte

nt (gram

s) Data Source

Import ed 157,70 7 0.82165 347 Aracr

uz THK TCDD ND (0.3 ppt) 17 0 0 0 P&RS 2004 File Data 2,3,7,8 TCDF 16 0.37 0 0.058 352 1,2,3,4,6,7,8 HpCDD 10 0.32 0 0.050 466

NCASI 1,2,3,4,6,7,8,9 OCDD 12 4.06 0 0.640 29 1,2,3,4,7,8 HxCDF 3 0.03 0 0.001 183 1,2,3,6,7,8 HxCDF 4 0.03 0 0.001 183 1,2,3,7,8,9 HxCDF 5 0.03 0 0.001 183 2,3,4,6,7,8 HxCDF 6 0.03 0 0.001 183 1,2,3,4,6,7,8 HpCDF 1 0.13 0 0.010 251 1,2,3,4,7,8,9 HpCDF 2 0.13 0 0.010 251 1,2,3,4,6,7,8,9 OCDF 11 0.08 0 0.012 617

I hope this meets and exceeds your questions.

Regards,

Mike Childress Mehoopany Environmental Group The Procter & Gamble Paper Products Co. Phone: (570) 833

- 3306 Cell: (570) 240

- 0389

From: Kimberly Landick To: childress.mg@pg.com Date: 11/09/2011 3:04 P M Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for providing the additional information. We understand that the Dioxin Congener Reporting Tool is a company tool used to rep ort the congener

- specific release amounts. You state below that the tool uses P&G pulp analysis data that provide the congener

- specific speciation for each pulp. What is the P&G pulp analysis data basedon (e.g., direct sampling, literature, etc.)? Could w e receive a copy of the data? Additionally, what is the source of the estimated release amounts and could we also receive a copy?

Please call me at 703

- 633

- 1119 to discuss the answers to the questions above so we can better understand the underlying calculations. Again, thank you for your response.

Kimberly

From: Michael Childress To: Kimberly Landick Date: 11/07/2011 3:55 PM Subject: RE: Request for 2009 TRI Data Clarification

Kimberly,

Dioxin Congener Reporting Tool

–
The Dioxin Congener Reporting Tool assists the facility in reporting for the Dioxin Form R

- Schedule 1. The facility inputs the pulp usage data and also inputs the total grams released to each environmental media. The Tool uses the P&G pulp analysis data (these data provide the congener

- specific speciation for each pulp) and the facility

specific pulp usage data to determine a weight percentage usage for each of the 17 dioxin congeners. This weight percentage breakdown is then applied to each estimated rel ease value to provide a dioxin

- congener specification of each reportable release on the Dioxin Form R

– Schedule 1.

Hope this helps,

Mike Childress

Mehoopany Environmental Group

The Procter & Gamble Paper Products Co.

Phone: (570) 833

- 3306

Cell: (570) 240

- 0389

P lease consider the environment before printing this e

- mail.

From: Kimberly Landick To: childress.mg@pg.com Date: 10/31 /2011 11:34 AM Subject: RE: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for providing the information below. We have one follow

- up question in order to correctly interpret your

answers:Please explain the Dioxin Congener Tool that is used for calculations. We realize that it allows for the reporting of the congener

- specific release amounts but would like to clarify the values that are used. Please provide an example.

Again, thank you for your response.

Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com Phone: 703

- 633

- 1119

From: Michael Childress To: Kimberly Landick Date: 10/26/2011 2:20 PM Subject: RE: Request for 2009 TRI Data Clarification

Kimberly

- First I would like to clarify that we are a large consumer paper production plant that utilizes other manufacturers to supply our pulp. The pulp material has resident dioxins and its congeners. The total amount of pulp used with its dioxins and congeners is understood and using a calculation determines the amount of dioxin and its congeners released to our effluent water. The dioxin already exists in the pulp that is received at our facility. Procter & Gamble (P&G) is aw are that under the EPA TRI program, dioxin does have a qualifier that
states:

Dioxin and dioxin

- like compounds (manufacturing; and the processing or otherwise use of dioxin and dioxin

- like compounds if the dioxin and dioxin

- like compounds are present as contaminants in a chemical and if they were created during the manufacture of that chemical.)

The dioxin in the pulps received by P&G are already contaminants in the pulp and do not meet the qualifier; however the pulp (and the dioxin) is imported which is considered manufacturing under TRI. Clarification has been requested by EPA as to whether the manufacturing by importation of the dioxin meets the qualifier or not. Clarification has not yet been recei ved. Therefore, P&G considers the imported pulp and dioxin as being reportable and not meeting the qualifier.

With that being said, please find for your review our answer to your questions below high

- lighted in green font.

1. Does the mill use hypochlorit e to bleach pulp? No

2. Please verify the 2009 dioxin discharges found in the attachment (Proctor & Gamble Mehoopany Dioxin Discharges.xlsx). Verified and confirmed correct.

3. Were the data reported for 2009 based on actual measurement(s) of effluent d ischarges? No

4. If not actual data, what was the basis for estimating releases to water? Dioxin congener tool for calculations. [When estimating the dioxin congener

- specific releases, the facility uses the congenerbreakdown in the pulps received and appl ies that to the estimated release amount. The dioxin congener tool allows for the reporting of the congener

- specific release amounts.] 5. How were analytical results at or below the analytical minimum level or detection limit treated (i.e., were < "less th an" values treated as zero, or as some fraction of the detection limit)? [P&G performs sampling on the pulps used by the facilities. When using these data for TRI threshold calculations and reporting, the following practices were followed: When congeners w ere non - detect, 0 was used. When congener data were not available, the facility would default to the most conservative congener data available for the pulps used on site.] 6. Did the mill recognize that EPA's TRI dioxin and dioxin/like congener numbering s equence changed for the 2008 reporting year and beyond? [P&G recognizes that the congener numbering sequence changed for reporting year 2008 and modified its reporting tools accordingly.]

Respectfully submitted,

Mike Childress Mehoopany Environmental Group The Procter & Gamble Paper Products Co Phone: (570) 833

- 3306 Cell: (570) 240

- 0389

From: Kimberly Landick To: childress.mg@pg.com CC: Codding, Eleanor; Sabol, Elizabeth; Swietlik, William BC: Landick, Kimberly Date: 10/19/2011 10:41 AM Subject: Request for 2009 TRI Data Clarification

Mr. Childress,

Thank you for your time on the phone this morning. Eastern Research Group, Inc. (ERG) under EPA Contract No.
68

- C

- 02

- 095 is emailing you on EPA’s behalf to request clarification of 2009 TRI data for the Proctor & Gamble Facility in Mehoopany, PA (TRI ID: 18629PRCTRROUTE). Please see below for further background.

EPA reviews TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise its water pollution control technology

- based regulations, called “effluent limitations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categories of industrial faci lities. EPA is currently conducting its 2011 annual review of existing effluent guidelines and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further inform ation). EPA will discuss this review and the results in its 2011 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of dioxin reported to the 2009 TRI. Please confirm/review the following data and questions below. 1. Does the mill use hypochlorite to bleach pulp? 2. Please ver ify the 2009 dioxin discharges found in the attachment (Proctor & Gamble Mehoopany Dioxin Discharges.xlsx). 3. Were the data reported for 2009 based on actual measurement(s) of effluent discharges? 4. If not actual data, what was the basis for estimating releases to water? 5. How were analytical results at or below the analytical minimum level or detection limit treated (i.e., were < "less than" values treated as zero, or as some fraction of the detection limit)?6. Did the mill recognize that EPA's TRI d ioxin and dioxin/like congener numbering sequence changed for the 2008 reporting year and beyond?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (703) 633

- 1119. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email: swietlik.william@epa.g ov

.

Thank you, Kimberly

---------------------------------------- Kimberly D. Landick Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 kimberly.landick@erg.com Phone: 703

- 633

- 1119

### Procter & Gamble Paper Products Co Mehoopany, PA
18629PRCTRROUTE

TRI Data

Grams Discharged Basis of
Estimate
0.0200029 E1

1 2 3 4 5 6 7 8 9

Total Water
Release Grams Discharged 0.0004927 0.000493 0.000313 0.0003125 0.0003125 0.0003125 0.00029 0.00029 0.00029

10 11 12 13 14 15 16 17 Total
0.0020535 0.001994 0.012139 0.0000323 0.0000256 0.0000258 0.000627 0 0.0200029

Questions: 1. Does this facility still operate their bleaching process? 2. What does the plant use for bleaching (e.g., sodium hypochlorite)? 3. What is the basis for the 2009 dioxin water release distribution (e.g., sampling)? 4. If the distribution is based on measured data,
4a. Were the concentrations below the detection limit? 4b. Where was the sample taken (e.g., bleach plant effluent, final effluent)? 2009 2009

Congener Number

### CASNU Congener Number
1746016 1
40321764 2
39227286 3
57653857 4
19408743 5
35822469 6
3268879 7
51207319 8
57117416 9
57117314 10
70648269 11
57117449 12
72918219 13
60851345 14
67562394 15
55673897 16
39001020 17 Heptachlorodibenzofuran, 1,2,3,4,7,8,9- Octachlorodibenzofuran Dioxin Congeners

Hexachlorodibenzofuran, 1,2,3,4,7,8- Hexachlorodibenzofuran, 1,2,3,6,7,8- Hexachlorodibenzofuran, 1,2,3,7,8,9- Hexachlorodibenzofuran, 2,3,4,6,7,8- Heptachlorodibenzofuran, 1,2,3,4,6,7,8- Heptachlorodibenzo-p-dioxin, 1,2,3,4,6,7,8- Octachlorodibenzo-p-dioxin Tetrachlorodibenzofuran, 2,3,7,8- Pentachlorodibenzofuran, 1,2,3,7,8- Pentachlorodibenzofuran, 2,3,4,7,8- Tetrachlorodibenzo-p-dioxin, 2,3,7,8- Pentachlorodibenzo-p-dioxin, 1,2,3,7,8- Hexachlorodibenzo-p-dioxin, 1,2,3,4,7,8- Hexachlorodibenzo-p-dioxin, 1,2,3,6,7,8- Hexachlorodibenzo-p-dioxin, 1,2,3,7,8,9- Chemical Name